Key takeaways
Washington's Department of Health proposed rules that rename compliant medical products "medical grade" and make terpene testing mandatory for them.
Heavy metal limits for medical grade products would drop well below current state limits, for example arsenic from 2.0 to 0.20 μg/g.
DOH estimates terpene tests at $25 to $35 per batch and says small producers and processors could be hit hardest.
The public hearing and comment deadline are both Nov. 10, 2026. DOH's intended adoption date is Nov. 17.
Washington's medical cannabis product rules are getting their broadest update since 2016. For producers and processors that put the state's medical logo on their products, the proposal means stricter contaminant limits, a new required test and more information on labels and QR codes.
The Washington State Department of Health (DOH) filed the proposal on Oct. 6, 2026, as WSR 26-20-094. It amends chapter 246-70 WAC, the rules for medical cannabis product compliance, and adds a new section on tax exemptions.
What the Washington medical cannabis proposal changes
The three product classes stay: general use, high THC and high CBD. Each would be relabeled "medical grade," with redesigned DOH logos. DOH plans a sunset period so businesses can use up existing logo inventory.
The proposal applies to products seeking the medical grade designation, not every adult-use product on the shelf, as The Marijuana Herald notes. Products that fail the new limits couldn't carry the DOH logo.
New heavy metal limits for medical grade cannabis
The proposed limits compare with the Liquor and Cannabis Board's current standards in WAC 314-55-102 like this:
Metal | Current LCB limit (μg/g) | Proposed medical grade limit (μg/g) |
|---|---|---|
Arsenic | 2.0 | 0.20 |
Cadmium | 0.82 | 0.20 |
Lead | 1.2 | 0.50 |
Mercury | 0.40 | 0.10 |
The proposal also sets a benzene failure point above 1 μg/g, and fails unprocessed plant material if bile-tolerant gram-negative bacteria exceed 1,000 CFU/g. All testing must still go through a lab accredited by the state agriculture department and certified by the LCB.
Terpene testing and label changes
Terpene testing becomes required. Labs must quantify at least nine terpenes when present above 500 μg/g, including myrcene, limonene, linalool and caryophyllene. For flower, the test applies whenever the LCB requires cannabinoid potency testing.
"For useable cannabis and cannabis concentrates, the label must include the concentration of the three most prominent terpenes."
Labels would also need a harvest date for flower and a production date for concentrates and infused products. The existing link or QR code would have to lead to the certificate of analysis and a list of pesticides and other substances used. Medically endorsed stores would have to provide a paper COA when a patient or designated provider asks.
High-CBD product thresholds
The high-CBD class gets looser on THC. Extracts now capped at 2% THC with at least 25 times more CBD could hold up to 15% THC with at least five times more CBD. Solid edibles move from 2 mg to 10 mg of total THC, still with five times more CBD. The new tax section says medical grade high-CBD products bought at a medically endorsed store are exempt from retail sales and use tax.
What it could cost
DOH puts terpene testing at $25 to $35 per batch, based on lab price lists. It calls other costs, such as lab method validation, larger labels and website updates, indeterminate. The agency concluded the rule may impose more-than-minor costs and fall hardest on small businesses.
What this means for operators
Pull your recent COAs. Compare your metals results with the proposed limits to see which medical grade SKUs would still pass.
Price terpene testing. Ask your lab what it will charge per batch and whether its methods are validated.
Audit labels and QR pages. Check room for top-three terpenes, harvest or production dates, and COA and pesticide disclosures.
Comment by Nov. 10. Send written comments to DOH or join the Zoom hearing at 11 a.m. that day.
What this means for cannabis workers
If you work in a medically endorsed store, expect new logos, more patient questions about terpenes and more requests for paper COAs. Lab staff could see more validation and testing work. The proposal also bars medical grade labels from stating or implying a specific medical benefit.
The bigger picture
DOH says the rewrite follows 2022's switch from "marijuana" to "cannabis" in state law and a 2024 law on medical tax exemptions. The agency counted 161 producers, 221 processors and 816 producer-processors licensed in fiscal 2024, and knew of only four labs testing cannabis in Washington as of Sept. 29, 2026.
Related on The Weekly Joint: Colorado's cannabis testing audit · More product safety coverage · Browse all issues
Sources
This article is general information, not legal advice. Questions about the rulemaking can go to DOH's medical cannabis program at [email protected].
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